ML20105D243
| ML20105D243 | |
| Person / Time | |
|---|---|
| Site: | Surry, 05000000 |
| Issue date: | 06/24/1983 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20105C697 | List: |
| References | |
| FOIA-84-574 364, NUDOCS 8502090626 | |
| Download: ML20105D243 (15) | |
Text
spur VIRoINIA ELECTRIC AND POWER COMPANY Rscuxown, VIRGINIA 20263 w.L.srs w ar wuYt...o..'.. Eon.
Juna 24, 1933 Hr. Janies p. O'Roilly Serial Nn. 364 Regional Administrator N0/WDC:acm Region II Docket Nos. 50-280
- b. 3. NSimot R.aul.Lv., 0 -
1.~ 1...
50 281 101 Marietta Street, Suite 2900 License Nos. DPR-32 Atlanta, Georgia 30303 DPR-37
Dear Mr. O'Reilly:
SPECIAL REPORT OF RADIATION EXPOSURE SURRY POWER STATION This report is Deing ritea pursuant to the requirwments of 16 CFR 20.405(a)(1) and concerns the exposure of five (5) individuals to radiation in excess of the limits specified in 10 CFR 20.101(a) without proper documentation as required by 10 CFR 20.102.
In response to a request for exposure litivou tion, the radiation exposure record of a former radiation workar was examined.
The record revealed that the individual received a dose of 2.361 rem during the second quarter of 1983 while assigned to Surry Power Station. Contrary to the requirements of 10 CFR 20107(b), a form NRC-4 was not completed and signed by the individual nor was ths individual's previously accumulated occupational dose and the additional dose allowed properly documented.
Although other documentation in the individual's record contained the total occupational dose previously received by the individual, this documentation did not ensure full compliance with 1 20.102(b).
iherefore, the individual's vapuvute of 2.361 tem (.hvl= Lody) exceeded the applicable limit of 1 20.101(a).
The above discovery prompted a review of the exposure records of all individuals terminating work assignments during the current calendar quarter.
Four additional records were found to l.
contain identical deficiwucien la seguised ytiva dvoc documentation.
laese four individuals had received second quarter doses of 1.558 rem, 2.067 rem, 2.033
- tem, and l1.151 s cus.
T1... u f vi. LLs sh p.v4 of eha four addie testal individuals also exceeded the applicable limit of 1 30.101(a),
i The limit of 1.25 rem per quarter was exceeded without proper documentation due to a feature of the computer-based system which controls additional exposure authorization.
This feature allowed the use of outdated information resulting in improper authorization for additional exposure.
The failure of shift personnel to thoroughly review the personnel records also contributed to this discrepancy.
The subject individuals had worked at Surry Power Station during the first quarter of 1983.
The computer-based exposure records created during that period contained an entry which indicated that a form NRC-4 was on file. When 8502090626 840809 PDR FOIA MAYBERRB4-574 PDR
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, vimig A hactaic awn Powna cowrm fc James P. O'Reilly these individuals terminated their work assignments, their records were placed in an inactive status within the computer.
Upon their return during the second quarter of 1983, it was possible to return their records to an active status since these records had not been purged from the computer memory.
The computer entry which indicated that a form NRC-4 was on file remained, thus, an authorization for exposure in excess of the limits specified in 1 20.101(a) was allowed.
Had an entry to indicate that a form NRC-4 was not on filo bocn made at the time of termination, the authorization could not have been produced until an updated form NRC-4 had been completed.
A change to the termination procedure has been implemented which requires, as a final step, an entry into each individual's computer-based record that a form NRC-4 is not on file.
This will require that a current form NRC-4 be completed each time an ind1Y1dugl rtturDH to the Ararinn fnr vnrk assignment.
Pursuant to 10 CFR 20.405(b), Attachment 1 provides information for each individual exposed. is a separate part of the report and is to be withheld from public disclosurw.
In accordance with 10 cFx 20.409, this letter notifies each individual of rheir exposure concurrent with notification to the Nuclear Regulatory Commission.
Very truly yours, tv iv';
W. L. Stewart Attachment (to be withheld)
Mr. Richard C. DeYoung, Director cc:
Office of Inspection and Enforcement Mr. D. J. Burke NRC Resident Inspector Surry Power Station
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e vinorvia Etiente Awa Powza CoWPAwY TO James P. O'Reilly ATTACHM2NT 1 Infunnativii Subj=st to Withhsiding from Publi_e D_ioelocuro As required by 10 CFR 20.405(b) the following information is provided as a separate part of this report.
Individuals' Name:
Ridley, Timothy Social Security No:
227-98-4990 Date of Birth:
07-07-58 Second Quarter Dose:
2.151 Rem Individuals' Name:
Bentfeld, William T.,
Jr.
Social Security No:
226-06-7371 Date of Birth:
06-08-61 Swcond Quarter Dose:
2.067 Rem Individuals' Natee:
Barnes, Warnett Social Security No:
227-86-5636 Date of Birth:
11-11-30 Second Quarter Dose 2.361 Rem Individuals' Name:
Harris, Christopher A.
Social Security No:
104-58-4594 Date of Birth:
08-12-60 Second Quarter Doser 2.035 Ram Individuals' Name:
Anderson, David L.
Social Security No:
225-74-5120 Date of Birth:
04-19-59 Second Quarter Dose:
1.558 Rem 6
/ d' To E/U(GoA1 C rom s4 W I
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i-ND RECE14us s
NOV 8 Go3 nona mms a ucm coew, a re.au m e2 opns wrr.m INTER OFFICE CORR ESPONoENCE wrio,, Turkey Point-Nuclear Novader 1,1983 bl
'D.W. Haase 78 DAT8 Of g/t'[
P.W. h ghes ce,,sto J.L, Dansk
- ' rmm R.M. Brown
- suudt, CCaux.ns scrICN-4JNA11Df0RIZED T. A. Colamn RDCIOR SIDIP arIRY J,R. Bates
'Iha Health Physics Daph, wet is in the gesssa of inplarenting-the follcwing corrective actica to srevent recurra1ce of the recett unauthmized reactor suas entry and to grevent any future unauthmized entrias into potettial darwcas, Isthal radiation fields. See actions will require
=.
A resoluticn., I respectively request review.and advice towards these corrective-acticns.
T.0 A specific trainlyclass on reactor in care detectx systers will be develc9ed for Health Ptt(sics Technic 1&ns and Superviscrs.
Etia refresher training class will be corducted the week of Nor-innl:ar 28 1983.
2.0 The Health Physics Dugartamat wi.L1 &=lt with ocrporate Health-w o. c o th. - t o d. fin a o -.>,- 4 a rea m m e n o.1.
Physics manual and g "N.
This will be ec-s ainated with l
PSL.' CCaplation date 11-4-83.
3.0 He will define the following arena as esclusicn areas. Access i
to tbese areas shall be whelled her cme site specific lock.
Actual.kay control and overall managaunt phiim needs to be resolved.
j 3.1 93 React a su p 3.2 94 Deactar Sep 3.3 53 Pressuriser at Power 3.4
- 4 Pr.
- nrizar at power 3.5
- 314' elevation bio-ell entrances (2) at power 3.6 4414' elevaticn bio-wall entrances (2) at power e
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tggy t O. ', ts'4 10:49 t;Q L I P t. LuF P.02 f 9, 1 9'? 2 ~
11/18/88 kPPt.9tEMTAL INFORMATion OM ACTIONS TAKEN RELATED 10 UNAUTHORIZED REACTOR SUMP E1 @
Prior to Enforcosent Conference (Wed.11/9/83) the following evaluations / actions were taken:
(1). Healtti physics verified that all other high radiation areas (HRA).
and locked htgh radiattom armas (LHRA) had active AWP's. (i.e '
H.P. coverage in lieu of an RWP is not abused).
(2). Other areas including the reactor cavity sump were identiffed'for
~
engineering waluation to further restrict access (see meno from Hughes to Masse).
One Day After the thfbreement Conference (Thurs. 11/10/83) the following evaulation/ actions were taken:
(1). Health Phystet Supervisor held meeting'.with it.P. techs on na more '
f H.P. coverage in Tieu of an AWP for HRA and LHRA.
'i (2). Plant Manager initiated a reytow by technical department of extsting procedures that allow MP coverage in Ties of an RWP for HRA and'1.HRA. Procedures identified were changed and subattied to PNSC for review tod approved on 11/17/83 (first FNSC'. meeting since i
enforcement conference).
Note:
All HRA and LHRA at the plant have an active RWP for entrance (except for reactor cavity sump which is locked and' HPS has only key). An' stated above thfs was in piece prior-to enforcement cunference.
conecnw acam-carnizm IEACIOR SJMP E!ERf (CDTf.)
Page 2 of 3 3.7 53 CVCs letdown daninaralizar recra 3.8
- 4 CVCs Istdom <5mninaralizer access gate (inner gate to daninaralizer) 3.9 93 s f4 Base caticri daminsr=14= recm
~
. 3.10 Rai hste W MinJ South Evapcrator Rcem 3.11 10' elevatica resin discharge piping area, east P4mwear 3.12 13 & le Wr rocas at pcwer 4.0 A$d hold. points to appropriate OperaHenal and I & C proce&res to ensure reactor stup grating is locked prior to extractire thimbles and stare locked until thimbles are iraerted. coupletica date 11-11-83.
5.0 Develop specific cperating instruchima swaing reacte may entries far Health Physim Shift Supervlaars and Technicians, umse instructicus will be reviewed during the ucNember HP Training session.
6.0 Review past I & C bulletins to ensure we have satisfactorily satisffad requiranents of these bulletins. C 7 1ation data 11-30-63.
7.0 Dania FM algns for rematce same entrance door ad 3mer grating gate to ideritify corditicms in the reacts map. Completion data 11-11-83.
8.0 ccmsult with Technical Depmht and implement the folicwing high priority REA's 8.t.
Design / fabricate Whla grating gate and install a.
spot ligtit over Units 63 and 64 reacta cavity sung entrances. (Alren% in scogress.';)
8.1 ~ Design /fatricate fer+=him gates across Ohits 93 ami te 14' elevatim bio 9ml1 entrances (2 each). To be used during power cparatien.
8.3 Design /fatricate lockable barriers fm Units 53 and' 44 reactor cavity ad 3resarizar entrances durire power cperation, ccmsideratim shculd be given to removing i
reacta cavity 1* Iricr to power cperaticm.
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COPPICIVE PCIIOMNAUPIORIZED IOCIOR SIMP DTTE (CINf.)
Page 3 of 3 8.4 Design /specify gcpar sign material, paint omtings and insta11 Atien net!r.ds to allcw warning signs to be left in reir*MM at power.
8.5 Design /fabrisata cable barriers to preclude entries across manisulatcr crane wa.Ucey at power. Alpeevei W sigrt to be insta11M en barrier.
8.6 Install, appropriate warning signs cn new reactx:r cavity handrails. To be usei during power operaticn.
8.7 Design /fabriacto cable barrier to preclude entrance to flux ampper area at power, Asqproved wrning sign to 1:e installad.
8.8 Design /fairicate Icckable grating barriara to In:ecInde acoass to resin discharge piping at east and of 10' elevation pipe chase.
8,9 Design / fabricate fencing and IWbla gate across high level filter atorage area in Rad Wasta Building.
8.10. Design /fairicata Icckable gratJng gata M thits #3 and-54 spent:. Maal' Pit dominarmii==rs.-
9.0 Ebsure th3s episode is reviewei during cperator training class.
kt4kk.
P.w. me PHu/xt c
UNAUTHORIZED REACTOR SIMP ENTRY AGENDA NOVEMBER 9,1983, MEETING WITH NRC REGION II 1.
Description of Event:
Plant Conditions:
5 Unit 3:
In refueling shutdown with reactor defueled, the in1 core detector thimbles retracted from the reactor vessel with Control Room indication of containment sump filling up at greater that 1 gpm.
Unit 4:
Off-line Sump Entry:
The Unit 3 reactor sump area was unlocked and entered by the Shift Technical Advisor (STA) and a health physics technician at approximately 11:30pm on Friday, October 14, 1983, in order for the STA to look for the source of the leakage (making his rounds.
The STA received 1300 mram whole body dose (as determined by process)ing his TLD) and the H.P.
technician received 200 mrem (by self-reading pocket dosimeter) whole body dose from this entry.
Immediate Corrective Action:
The STA was immediately removed from the sump area and the containment and was restricted from the RCA. His TLD was processed to determine his dose. The entrance to the sump area was relocked.
4 II.
Investigations and Findings:
Investigation results:
1.
The reactor sump area with the in-core thimbles retracted had a l
general area dose rate of 50 Rem / hour and was locked (at all times) and posted as a high radiation area and an Exclusion area at the time the thimbles were retracted (i.e. prior to the entry by the STA and
)
the H.P. technician).
2.
The general area dose rate in the sump area depends on whether the in-core detector thimbles are retracted.
If retracted, the dose rate i
is about 50 Rem /hr, if they are inserted about 50-100 mR/hr.
The general area dose rate on the 14' elevation (inside the locked enclosure) is approximately 50 mR/hr with the thimbles retracted.
3.
There was no Radiation Work Permit approved specifically for entrance into the sump area (elevation ~ 6') nor had the area been. surveyed by HP. Health Physics coverage was provided for entry into the enclosure (elevation 14') and the STA had a portable radiation survey instrument.
Note: Entry specifically into the sump area was NOT AUTHORIZED.
l
4.
The STA assumed since the HP Technician let him enter the sump area that it was okay to do so.
5.
The Technical Department training and overall STA requirement in the area of health physics was re-evaluated and considered to be adequate.
STA training does include training on in-core map flux detectors.
Also red badge training includes training related to locked High Radiation Areas.
==
Conclusions:==
1.
The doses to the STA and the HP Technician did not exceed any allowable limits.
The STA received 1300 mrem (for the quarter) and had an allowable limit of 3000 mrem (completed NRC - 4 fonn).
The HP technician's accumulated dose for the quarter (including this entry) was 450 mrem and was also on a 3000 mrem quarterly limit.
2.
The STA was aware of the conditions via the posting on the door.
He demonstrated poor radiation protection practices while entering the sump area (improper use of radiation survey instrument) and went beyond the bounds of the RWP. He was provided HP coverage when entering the enclosure as allowed by procedure and standard industry practice.
The HP technician was also cognizant of the radiological conditions
.in the sump and was instructed on the existing conditions. [(1)
Instructed by the FPL-HP contairnent supervisor not to go down the sump but to just look down the shaft with a flashlight because the thimbles were pulled.
(2) Posting on locked entrance doorway to the sump area identifies exclusion area and working on in-core detectors.] The HP technician also demonstrated poor radiation protection practices by allowing the STA to enter the sump area i
first.
III. Corrective Action:
l A.
Interim:
(1) Shift meetings were immediately conducted Saturday, October 15, 1983, with all the HP Technicians. The seriousness of such an i
entry and proper procedure was reviewed with all personnel.
(2) Reactor sump door was reposted requiring direct approval of the HP Supervisor or the HP Operations Supervisor for entry.
(3) A new key core ordered prior to the incident was installed in
~
the reactor stnp door. Presently the HP Supervisor.has the only key.
(4) The HP technician was terminated.
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(5) As a result of the investigation the STA's annual performance review was lowered and he was removed from his STA duties until released by the Technical Department Supervisor and the Plant Manager.
Also the STA's red badge was pulled requiring reattendance and testing in the general employee radiation protection training program.
(6) An evaluation was initiated for the design and fabrication of a permanent grating gate over the sump entry way.
8.
Long Term:
(1) A specific training class to re-emphasize reactor in-core detector systems will be given for Health Physics Technicians and Supervisors.
This refresher training class will be conducted the week of November 28, 1983.
(2) Reevaluate existing operating instructions concerning entries into locked High Radiation Areas.
(3) All operators, including the STAS, will review this incident during operator requalification training.
(4) Design special signs for reactor sump closures to identify conditions in the reactor sump. Completion date scheduled for December 1, 1983.
O e
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^
IV. Background Information:
"Overexposures In PWR Cavities", was distributed to all licensed personnel on 2/7/83, as recommended in the notice. Also the health physics department reviewed existing procedures j
to ensure positive control would be maintained when the thimbles are i
retracted.
Specifically, operating procedure 1407.21, " Refueling Activities Check-Off List", requires a sign-off that maintenance procedure 12407.1 be followed when retracting and inserting thimbles.
l Maintenance procedure 12407.1, " Retracting And Inserting Incore Instrumentation Thimbles," requires (by sign-off) that an RWP is required prior to performing this task and that the NPS be notified prior to commencing this job. Also the procedure states (by sign-off) to ensure the containment sump area is clear of all personnel, door locked and HP notified of work to be done. At that time Health Physics also decided to install a new key core in the entrance door to the sump area in order to restrict key access into the area.
The key core was ordered in May and due to receiving the incorrect order was not installed until October 17, 1983. Presently the HP Supervisor has the only key.
All controls were in place prior to this incident occuring:
(1) RWP 83-372, " Unit 3 Containment Retract / Insert Flux Mapper Thimbles At Seal Table", was in effect on 10/8/83.
Specifically, special instructions on the RWP state, " Verify no one is in reactor sump prior to retracting thimbles-request HP to post reactor sump as
" exclusion area".
(2) The entrance door to the reactor sump area was locked and posted as stated in the RWP. As described by the above procedural steps health physics was aware when the thimbles were retracted and the entrance door was locked and posted accordingly.
The health physics technician covering the inspection was notified of the condition in the sump and was aware of this condition when he made entry.
Therefore we feel this incident occurred due to the HP technician seriously violating standard HP practices and specific instructions.
We also feel that the STA demonstrated poor radiation protection practices while entering the sump area.
Failure for him to follow good radiological practices when entering the sump area demonstrate the need for re-emphasizing training in this area.
(3) The severe personnel action taken against the two employees involved is intended to let the work force know the company's position on l
following proper radiological controls and procedures.
The health physics technician covering the inspection was a contract technician taking specific instructions from an FPL-HP-Supervisor. The ididividual had over 6 years experience in commercial nuclear power plants, was a senior technician and was extensively tested by FPL prior to hiring.
Corrective actions to prevent recurrence for this specific case as well as i
other potentially similar situations are addressed above.
i
V'.
Significance of Event We recognize the significance of this event and the potential for overexposure.
In previously reviewing established procedures and the control mechanisms they implemented (including sign-offs) we felt that adequate controls were in place with additionally provided health physics coverage.
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